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Technical Comments on the Revised Application to Modify International Paper, Ticonderoga Mill's Title V Permit to Conduct a Two-week Tire-Derived Fuel trial.

Submitted by the Board of People for Less Pollution to the NYDEC

8. The revised permit application does not  adequately address water pollution and solid waste disposal issues arising from the test burn. IP’s letter to the NYDEC regarding waste water impacts of the test burn does not include any data to support the projected 50%  zinc removal efficiency by the the wet scrubber.  It is not clear how the assumed 73% control efficiency for zinc and metals in the air permit relates to the projected 50%  zinc removal efficiency by the the wet scrubber. Estimates of  scrubber removal efficiency for other metals are not provided in the letter. The zinc mass balance calculation alluded to in the letter is not presented in the letter, thus making it impossible for the general public to asses  the validity of the mass balance calculation. The letter does not state where and how pH in the wastewater treatment facility will be monitored and does not propose to do internal testing to measure the actual effectiveness of the precipitation of  zinc and metals. The sampling design for testing the impact of the TDF trial on the plants wastewater discharge is not adequate.  Zinc and metal testing should be conducted much more frequently if there is a test burn. Daily zinc testing with one day turnaround for results means that the plant could exceed the zinc action level for 24 hours before plant personnel would even be aware there was a problem. More intensive emission monitoring is particularly important because it is highly likely that IP will reach PSD actionable air emission limits during the test.  A single scan for priority pollutants and whole effluent toxicity when the plant is burning TDF at the maximum rate is also wholly inadequate. A single sampling will not include periods when varying amounts of TDF are being burned and control efficiency is known to vary with feed rate. It is essential to have priority pollutant and whole effluent toxicity  testing before, during and after any test burn in order to be able to relate any observed changes in water quality to the test burn. The letter mentions the long residence time of wastewater in the treatment facility but does not propose to conduct any water quality testing after the test burn is completed. The letter contains no information concerning (or attempts to model) the distribution and fate of pollutants released into Lake Champlain during the test burn.

9. The revised permit application does not contain an adequate discussion of how burning TDF will effect NOx emissions. In many cases in  the literature, TDF is replacing coal, not oil. In comparison to oil, coal, like TDF, is a solid and has much higher levels of ash and metals. The decline in NOx  emissions reported in the literature when TDF is burned may be a result of the elimination of coal.

 10. The potential for mercury emissions during the test burn is not seriously considered in the revised permit application. More of an effort should be made to track mercury  during the trial burn. Granted, there is little mercury in TDF, but there is little in the oil it is replacing as well. A change in operating conditions (such as will occur when changing the fuel mix) could change the mercury emissions.

11. The revised permit application does not adequately describe the pollution controls in use at the plant. The wet scrubber in place on the power boiler has a unique design that is not easily comparable to scrubbers at other plants. IP has not presented an adequate description of the design and operation criteria of the scrubber currently in place on the power boiler. Plant officials have described the scrubber "a Venturi like scrubber or a spinning basket scrubber".  Wet scrubbers, particularly those designed for gas (SOx) removal such as the IP-Ti power boiler scrubber, are generally not nearly as effective for particulate matter removal.  This is highlighted by the low removal efficiency reported in the IP permit documents (~75%).  A well designed scrubber for particulate removal should have >95% efficiency.

12.  IP has stated that between 80 and 90  industrial plants burn TDF but has provided no background information as to the type of plant, the amount and % of fuel burned as TDF, and the type of pollution controls in place on each plant.  It's not possible to compare the IP plant to other facilities burning TDF without this information.  The 1999 EPA Report compiles the results from TDF trials at a number of facilities, including some paper mills.  Note that the particulate emissions for ALL the pulp/paper facilities increased when TDF was added to the fuel mix.

13. International Paper's burning of tire-derived fuel without an ESP has not taken into account new particulate standards proposed and under consideration by the EPA. EPA staff has recommended, and The Clean Air Scientific Advisory Committee CASAC has endorsed, a new standard for coarse particles that are also small enough to be inhaled into the thoracic region of the lungs. Called PM 10-2.5, coarse particles are smaller than PM 10 but larger than PM 2.5.  Particles of this size range are associated with respiratory illness. In the draft Staff Paper, the EPA staff scientists recommended cutting the daily standard by half, perhaps in combination with a reduction in the annual average standard.  Two options were presented: Option A:  Retain the 15 µg/m3 annual standard, while lowering the daily standard to between 25 and 35 µg/m3; or Option B: Lower the annual standard to between 12 and 14 µg/m3, while lowering the daily standard to between 35 and 40 µg/m3. EPA staff scientists also discussed strengthening the form of the standards. The form establishes how many times and how frequently a county can have higher levels of pollution than the standard level when calculating compliance. EPA is under a Consent Decree to issue a final Staff Paper by June 30, 2005, a proposed rule by December 20, 2005, and a final rule by September 27, 2006.

Technical Comments on The IP Draft Permit to Burn Tires

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